NOTE: Note that this is an evolving situation, and this page will be updated as more questions arise and rules are clarified. These are the answers to questions received, but they are subject to change as health care regulations are amended. Also, please be advised that the Systems Office is working on a report to track eligibility to aid departments with this endeavor.

Eligibility

Who does the ACA impact?

Anyone working an average of 130 or more hours per month over the measurement period or who is hired, as of July 2014, with the intent to work 130 hours or more per month.

Who do we have to cover under the ACA?

Only employees and their dependents need to be covered. Spouses and domestic partners do not.

If an employee leaves the University and then gets rehired, do we have to count their previous time worked during the measurement period?

Two rules apply to describe this “gap in coverage”. You may treat the employee as a new hire if:

  • The break in service was at least 26 consecutive weeks OR
  • The break in service was between four and 26 consecutive weeks and longer than the employee’s immediately preceding period of employment

Measurement Period

A student worker is hired at 15 hours a week, 75 hours per month in Department A, but after the measurement period was calculated, it was determined that the student worker was considered full time working an average of 130 hours per month and now the student worker becomes eligible for medical coverage.

While Department A may have kept the student worker under the 130-hour a month limit, the student worker may have worked somewhere else on campus during the measurement period and had more hours. During the measurement period, the overall average was more than 130 hours a month. Since the student worker is under your employment at the time of the stability period, your department must offer the medical benefits. If this is not what you intended, in the future, make sure to research the student’s prior employment to be sure it will not raise the average above the 130hours a month limit.

A casual worker is hired in the middle of the standard measurement period. How do we track the hours to see if he/she would be considered full time?

You will need to track two separate timelines:

  • A personal timeline that starts the day employee was hired and the regular timeline for ongoing employees.
  • The initial measurement period will run from the 1st of the month following the date of hire until the first year anniversary. There will be an administrative period of one month to sign up for benefits and then the stability period will last for one year.
  • At the same time, you need to look at how the employee ranks in the standard measurement period. So assume employee is hired in August. The initial measurement period is from September 1 through August 30. You will be looking at just the initial timeline. But when the annual standard measurement period begins, from July 1 to April 30, you will need to look at both timelines and see if the employee is full time in EITHER timeline. If employee is full-time in either or both of the timelines, the employee will need to be given benefits for the corresponding stability period.
A temporary employee worked for four months. How will the measurement period work? What happens with the benefit eligibility?

When new employees are hired, they start their own personal measurement period timeline. Their measurement period will last until their one-year anniversary. If they leave before their measurement period is over or before their stability period begins, the department does not need to offer the employee benefits or COBRA.

Stability Period

A temporary employee worked an average of 130 hours per month during the measurement period and is now eligible for benefits for the entire stability period. During the stability period, the employee’s hours have been decreased.

Yes. If an employee is found to be full-time during the standard measurement period, the employee will have medical coverage for the entire stability period, regardless of whether the hours drop. The new measurement period will track the decrease in hours, so during the following stability period, the employee will not be eligible for benefits. This requires constant tracking because the eligibility of an employee for benefits can change each year.

Benefits Related

What happens if a newly benefits eligible employee opts out of benefits during the administrative period, but later decides he/she wants medical coverage?

The employee will need to wait for the next open enrollment period or a Change in Family Status before he/she can sign up, just like a regular employee today.

How will people be notified that they are now eligible for medical coverage?

We are still working on this. HR will notify the employee’s supervisor.